The Code has no rule about artificial intelligence. What it has is a rule about taking on outside help, written for outsourcing back when the worry was a return prepared in somebody else’s office, and three interpretations that fire the moment you connect anything to a practice mailbox. They fit software better than you would expect, and badly in one place that matters more than the rest.
- The Code’s own AI material is labelled nonauthoritative and sits as a footnote under rules that predate the technology. Those rules are what you are actually judged against.
- The clause that bites hardest points at intake rather than disclosure: the basis under a conclusion you rely on, not the contents of a message you send.
- One of the three interpretations hands your client a veto, and it is the paragraph least likely to be in your file.
- The line between administrative support and assisting in the professional service runs through your settings, which is a strange place for a professional standard to live.
The Code has no rule about AI
Start with what the Code is for, because it is not the instrument people reach for it as. It does not regulate data, and it does not regulate software. Its subject is you: what you may take on, how carefully you must do it, whose judgment forms the result, and what you may say about a client. Whether you may connect a mailbox at all, and what to put to a supplier in writing first, is a different question with its own page.
It binds AICPA members. Whether it also reaches your licence is a fact about your state board rather than about the Code, and it is worth knowing which you are dealing with, because a board acts on a licence and the Institute acts on a membership.
Now look up artificial intelligence in it. The 2026 edition, updated for official releases through July 2026, carries this note under the General Standards Rule and again under the Confidential Client Information Rule: “A nonauthoritative article, Ethics Staff Insights: AI through an ethics lens, discusses threats to compliance with the code when members use AI to provide services.” Beside it sits a second pointer, to “Ethics Questions & Answers section 400.02, ‘Using the Output of Technology’”, also nonauthoritative (AICPA Code of Professional Conduct, checked 19 August 2026).
Nonauthoritative twice, in the profession’s own words. Writing in the Journal of Accountancy on 5 August 2026, Kelly D. Mullins put the position plainly: the Code “still provides clear, enduring guidance”, and members’ core responsibilities “don’t disappear just because new technology is involved”. No new rule is coming, and a firm that reads the AI commentary and skips the rules has read the part nobody is measured by.
So what happens when no rule is on point? The Code answers that too. In the absence of an interpretation addressing a circumstance, you apply the conceptual framework, and you are “considered in violation of the ‘General Standards Rule’ [1.300.001] if the member cannot demonstrate that safeguards were applied that eliminated or reduced significant threats to an acceptable level.”
Then read the threats the framework asks you to weigh, and notice what they all are. Familiarity is a long or close relationship with a client. Self-interest is a benefit from an interest in, or relationship with, a client. Self-review is failing to properly evaluate “a previous judgment made or service performed or supervised by the member or an individual in the member’s firm”. Undue influence is subordinating your judgment “to an individual associated with a client or any relevant third party”. Every one of them is a relationship with a person or a business.
Which is why the rule most people reach for does not reach. The Integrity and Objectivity Rule says a member “shall not knowingly misrepresent facts or subordinate his or her judgment to others”, and in the Code’s own vocabulary the others are people. There is no clause anywhere that says do not defer to a machine. That sounds like a hole, and it is not, because the duty arrives from a duller direction and arrives anyway.
The rule that carries the weight
The General Standards Rule is four sentences long and predates all of this by decades. Read against a mailbox that composes, each one lands somewhere different.
Sufficient relevant data. “Obtain sufficient relevant data to afford a reasonable basis for conclusions or recommendations in relation to any professional services performed.” This is the sharp one, and it points the opposite way from almost everything a practice reads about AI. The rest of that reading is about disclosure, about what leaves the building. This clause is about intake: what comes in, and what you allowed it to settle.
A summary is a conclusion with its basis removed. That is precisely why it is worth having, and precisely what this clause will not accept on its own. The moments are ordinary. Deciding a thread needs no reading because the line at the top says it is routine. Deciding a client has asked for nothing because nothing was raised to you. Carrying a figure out of an answer about an attachment and into a return without opening the attachment.
The workable translation is one sentence. A summary is allowed to decide what you read. It is not allowed to decide what is true.
Planning and supervision. “Adequately plan and supervise the performance of professional services.” Supervising a person includes being able to ask them why, and the answer tells you whether the work underneath is sound. Supervising a model gets you output and nothing behind it. So supervision collapses into inspection, and inspection of a fluent answer is the weakest checking there is. Which is why the data clause carries the load: you supervise this by re-establishing the basis, not by finding the result plausible.
Professional competence. “Undertake only those professional services that the member or the member’s firm can reasonably expect to be completed with professional competence.” Nobody expects this one, because it reads as being about your own qualifications. The firm’s capacity is what it measures, and the software is now inside that capacity. A practice that takes on thirty more returns because the correspondence stopped being the bottleneck has moved the premise of this clause rather than satisfied it. That is a November thought, and it is worthless in March.
Due professional care. The standard with no moment attached to it, which is what makes it hard. Nothing triggers it. The moment worth noticing is the one where you would have looked and did not.
The other half of this, a draft whose envelope is right and whose facts came from somewhere else, is a different failure needing a different habit, and it has its own page.
Connecting a tool is the outsourcing question
The Code does have a body of rules for handing work to somebody outside the firm. Three interpretations, added when the profession was worried about returns being prepared in another office, and all three now sitting in the path of a firm connecting software. Whether they apply to a product rather than a person is not answered in terms, and the workable reading, the one the Institute’s own AI material takes, is that they apply when the thing is assisting you in providing the professional service.
Take the General Standards one first. Before using a third-party service provider, you “should ensure that the third-party service provider has the required professional qualifications, technical skills, and other resources”, and the Code offers factors: references from banks, other CPAs and other customers, “professional reputation and recognition in the community”, “published materials (articles and books that he or she has authored)”, and your own personal evaluation.
He or she. Half of that list cannot be applied to software at all, and the substitute, a written interrogation of the supplier, is a separate exercise the Code does not describe.
The other half translates without any strain: you “must adequately plan and supervise the third-party service provider’s professional services so that the member ensures that the services are performed with competence and due professional care”, and you “must also obtain sufficient relevant data to support the work product”. That is the half firms skip, because it is work rather than a purchasing decision, and it never finishes.
Then confidentiality. Before disclosing confidential client information to a third-party service provider, the member should do one of two things: “Enter into a contractual agreement with the third-party service provider to maintain the confidentiality of the information and provide reasonable assurance that the third-party service provider has appropriate procedures in place to prevent the unauthorized release of confidential information to others”, or “Obtain specific consent from the client before disclosing confidential client information to the third-party service provider.”
Either. The Code will take a supplier contract in place of the client’s permission, which federal law will not, so the two regimes disagree about the same act and both are live in a tax practice at once. A confidentiality agreement settles the Code’s question and does nothing for the statute, whose format rules are strict in a way the Code’s are not.
And the population is wider than the tax population. The rule is that a member in public practice “shall not disclose any confidential client information without the specific consent of the client.” Any client. Your bookkeeping-only clients and your advisory clients have no return information to protect and are entirely inside this one, which means a mailbox cleared for the filers is not a cleared mailbox.
The paragraph with a veto in it
The third interpretation is the one almost nobody has read, and it is the reason this page exists.
Under the Integrity and Objectivity Rule: “Clients might not have an expectation that a member would use a third-party service provider to assist the member in providing the professional services. Therefore, before disclosing confidential client information to a third-party service provider, the member should inform the client, preferably in writing, that the member may use a third-party service provider. If the client objects to the member’s use of a third-party service provider, the member either should not use the third-party service provider to perform the professional services or should decline to perform the engagement.”
Read the second half again. This is not a request for permission you may condition on being taken on. If the client objects, the tool comes off that engagement or the engagement goes back. A veto, held by a client who need give no reason, over a purchasing decision you made in August.
Then the escape, in the next paragraph: “A member is not required to inform the client when he or she uses a third-party service provider to provide administrative support services to the member (for example, record storage, software application hosting, or authorized e-file tax transmittal services).”
Look at what those three examples have in common. Every one is custodial. Something holds your material, or moves it from one place to another, and none of them touches the substance of what you were engaged to do. A tool that ranks a mailbox and files what arrives sits close to the second example and is genuinely hard to distinguish from it. A tool that answers a client’s question about their own return, or writes the reply carrying the figure, is not custody of anything. That is participation in the service.
Which produces the result worth carrying away. What decides which of those you have bought is not the product you chose. It is how far you have let each kind of work run, and that is a setting. The Code’s line runs through a configuration screen, and configurations change on a Tuesday afternoon without anybody re-reading an interpretation.
The Code gives examples rather than a definition, and where the line falls for your practice is a question for your own adviser rather than something to settle off a page. The shape is still usable. Custody is arguable. Composition is not.
So the practical instruction is short, and it inverts the order most firms work in. Tell them anyway. The notice costs a paragraph, the carve-out is arguable at best, and the objection you are inviting is one you would far rather receive in November alongside next year’s letter than in March with a return open on the desk.
The standard that names AI by name
For a tax practice there is a second rule book, and the Code is what gives it teeth. The Compliance With Standards Rule requires a member performing tax services to “comply with standards promulgated by bodies designated by Council”, and the Statements on Standards for Tax Services are those standards.
The revised SSTSs took effect on 1 January 2024, and SSTS No. 1 carries a section called Reliance on Tools. Its definition is worth reading whole, because of where one item sits. A tool includes “tax preparation software, tax research publications (paper or electronic), tax-related calculation aides, tax planning software, state and local tax aids, online data search engines, data analytics, statistical models, artificial intelligence, and relevant professional publications and resources” (Statements on Standards for Tax Services No. 1 to 4, checked 19 August 2026).
Artificial intelligence is in a list of things you look something up in. Every neighbour is a reference: publications, aids, search engines, models. The standards match the picture. “A member should exercise appropriate professional judgment and professional care when relying on a tool.” “Use of a tool does not absolve the member of professional obligations under AICPA or other applicable ethical standards.” A member who employs tools “remains responsible for the completed work product”, and “should take reasonable steps to determine that the tools used are appropriate for the intended purpose”. And the sentence that settles the argument about judgment: tools “should be used to enhance or improve the member’s understanding of a tax issue, not to supplant the member’s professional judgment”, because a preparer still signs under penalties of perjury, and “that responsibility cannot be transferred entirely to reliance on a tool.”
Every verb there is a consulting verb. Rely, use, understand. A thing you interrogate on your desk, which then goes quiet.
An AI email client is not that. It sits in your correspondence and acts, and the further you move a given kind of work from consulted to handled, the further past the standard’s picture you have gone, carrying more of “remains responsible” with nothing written down about how much. The same section adds that “the source of the tools must be considered when determining the appropriate level of reliance on that tool”, offering the example that a subscription research service may weigh more than an article found on the internet. A general model reading a client’s mailbox has no obvious place on that scale, and noticing you cannot place it is itself the answer about how much weight to give it.
Where does Point fit?
Everything above arrives at Point, which is one of the products those interpretations were never drafted for. What follows is where each question actually lands: a setting, a link, a record, a document.
- Which side of the carve-out you are on is a setting, and Point’s runs per kind of work. Suggest only, prepared and waiting on you, or handled outright. Every kind starts on review. Keep filing and ranking loose while client replies wait for you and the custodial reading stays arguable. Raise replies to the top and Point completes them without checking back, which is a different answer to the same question. Write down which way you have it, because that configuration is the fact the Code’s question turns on.
- The data clause wants a basis, and Point leaves one lying about. A summary or an answer drawn out of an attachment carries a link back to the message or the page it came from, so re-establishing the ground under a conclusion is a click instead of a re-read. That is the difference between a rule you keep and a rule you intend to.
- Supervision has to leave a trace, and Point’s is in plain language. What Point did is written down where you can read it, and most of it can be turned down or reversed. The exception is a message already delivered, which is sitting on somebody else’s server by then.
- The contract route is a document, not a security page. Point’s terms settle what happens to your content, and the standard service excludes regulated data, with tax return information named, unless a separate written supplement says otherwise. Subprocessors names the other companies rather than describing them. Ask for the supplement before you connect.
- A thread locked end to end is the one case where none of this arises, because Point cannot read that message, so nothing has been disclosed to anybody. The price is that nothing is ranked, summarized or turned into a task from it either, which is why it is a lane for a few messages a year rather than a way to run a mailbox.
The benefits page carries the whole inventory, and Point for accountants walks it in the language a firm uses. Point itself is the shortest version of the argument.
Common questions
Is there an AICPA rule about using AI?
Not one written for it, and the Code says as much about its own AI material by calling it nonauthoritative twice over. What binds you is older and blunter: the General Standards Rule, the three third-party service provider interpretations, and for a tax practice the section of the SSTSs that names artificial intelligence in a list of tools. Read those four things and the commentary stops being necessary.
Do I have to tell my clients before I connect an AI tool?
Under the Integrity and Objectivity interpretation you should, preferably in writing, unless what you have connected is administrative support, and the Code’s examples of that are custodial: storage, hosting, transmittal. The half firms miss is what follows. A client who objects can take the tool off their engagement or hand the engagement back, which makes this a heavier document than the notice that satisfies nobody’s statute, and a different document from the consent.
Is a contract with the vendor enough on its own?
For the Code’s confidentiality interpretation, yes, and that is unusually generous: you may enter a confidentiality agreement with the supplier or obtain the client’s specific consent, and either will do. For federal returns it is not enough, because the statute will not take a supplier’s promise in place of the taxpayer’s. And the notice obligation sits on top of both, so a firm holding a signed contract has settled one question out of three.
Can I rely on a summary instead of reading the thread?
To decide what to read, yes, and that is most of what you bought. To decide what is true, no, and the Code is specific about the reason: you need sufficient relevant data to afford a reasonable basis for a conclusion, and a summary is a conclusion with the basis taken out of it. The tax standard says the same thing from the other end, that a tool should improve your understanding of an issue rather than stand in for your judgment about it.
We are not AICPA members. Does any of this reach us?
The Code binds members, so the first question is what your own board has adopted, and that answer is about your state rather than about the Code. Worth establishing, because a board acts on a licence and the Institute acts on a membership. The reasoning holds either way. These interpretations are the profession’s written answer to handing work to somebody outside the firm, and a supplier reading a client mailbox is that, whoever is holding the rule book.
The short version
- The Code has no AI rule and is not getting one. Its own AI material is labelled nonauthoritative, and the rules you are measured by say nothing about the technology, which is exactly why they still apply.
- Every threat in the framework you are sent to when no rule fits is a relationship with a person. Nothing in the Code forbids deferring to a machine, so the discipline has to come from the General Standards Rule instead.
- Sufficient relevant data is the clause that bites, and it points at intake rather than disclosure. A summary may decide what you read. It may not decide what is true.
- Connecting a tool is the outsourcing question, and three interpretations answer it: tell the client, evaluate and supervise, then either a contract or a consent. The Code takes a contract where the federal statute will not.
- The notice comes with the client’s objection attached, and the carve-out that removes it was written for custody. Which side of it you are on is decided by how far you have let the software run.
Two neighbouring questions this page leaves alone on purpose. Whether to connect a practice mailbox at all, which turns on what a supplier will commit to in writing, belongs to the client data guide. Which sort of product a firm is choosing between before any of this arises belongs to AI email for accountants. If the category is new, what an AI email client is defines it.